PB94-964057
EPA/ROD/R04-94/186
September 1994
EPA Superfund
Record of Decision:
Naval Air Station, Cecil Field,
Jacksonville, FL,
9/14/1994
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
SEP 14 1994
4WD-FFB
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Captain Kirk T. Lewis
Commanding Officer, NAS Cecil Field
P.O. Box 108 (code 00)
Cecil Field, Florida 32215-0108
SUBJ: Cecil Field Site 11
Dear Captain Lewis:
The Environmental Protection Agency (EPA) has received and
reviewed the final Interim Record of Decision (IROD) for the
pesticide disposal area, also known as Site 11. EPA concurs
with the Navy's decision as set forth in the IROD'dated
September 1, 1994. This concurrence is with the understanding
that the proposed action is an interim action and the need for
any future or final remedial action will be addressed following
the finalization.of the Baseline Risk Assessment (BRA) .
By providing concurrence on this plan EPA does not warrant
technical adequacy as set forth or implied in the IROD.
Additionally, EPA concurrence does not implicitly or expressly
waive any of it's rights or authority.
EPA appreciates the opportunity to work with the Navy on
this site and other sites at Cecil Field. Should you have any
questions, or if EPA can be of any assistance, please contact Mr.
Baft Reedy, of my staff, at the letterhead address or at (404)
347-3555 vmx 2049.
Sincerely,
Patrick M. Tobin, Deputy
Regional Administrator
cc: Mr. James Crane, FDEP
Mr. Eric Nuzie, FDEP
Mr. Michael Deliz, FDEP
Mr. Steve Wilson, SDIV
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INTERIM RECORD OF DECISION
GOLF COURSE PESTICIDE DISPOSAL AREA
SITE 11, OPERABLE UNIT 6
NAVAL AIR STATION CECIL FIELD
JACKSONVILLE, FLORIDA
Unit Identification Code (UIC): N60200
Contract No. N62467-89-D-0317
Prepared by:
ABB Environmental Services, Inc.
2590 Executive Center Circle, East
Tallahassee, Florida 32301
Prepared for:
Department of the Navy, Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29418
Alan Shoultz, Code 1875, Engineer-in-Charge
August 1994
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Section
TABLE OF CONTENTS
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Reid, Jacksonville, Rorida
Title
Page No.
1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1
1.2
1.3
1-1
SITE NAME AND LOCATION 1-1
STATEMENT OF BASIS AND PURPOSE 1-1
ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDY
1.5 STATUTORY DETERMINATIONS
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
2.0 DECISION SUMMARY
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2,
2,
SITE NAME, LOCATION, AND DESCRIPTION
SITE HISTORY AND ENFORCEMENT ACTIVITIES
PREVIOUS INVESTIGATIONS
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF INTERIM REMEDIAL ACTION
SITE CHARACTERISTICS
SUMMARY OF SITE RISKS
DESCRIPTIONS OF ALTERNATIVES
SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES 2
2.9.1 Overall Protection 2
2.9.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) 2-
2.9.3 Long-term Effectiveness and Permanence 2-
2.9.4 Reduction of Toxicity, Mobility, or Volume of
the Contaminants 2-
,9.5 Short-Term Effectiveness 2
,9.6 Implementability 2
10
11
2.12
9.7 Cost 2
9.8 State and Federal Acceptance 2
9.9 Community Acceptance 2
SELECTED REMEDY 2
STATUTORY DETERMINATIONS 2
DOCUMENTATION OF SIGNIFICANT CHANGES 2
1-1
1-2
1-2
2-1
2-1
2-1
2-4
2-7
2-7
2-7
2-8
2-8
-10
-10
-10
-10
10
22
22
22
22
22
22
22
23
REFERENCES
APPENDIX A: Responsiveness Summary
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MVL08.94
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LIST OF FIGURES
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Field, Jacksonville, Florida
Figure Title Page No.
2-1 Site Location Map 2-2
2-2 Study Area 2-3
2-3 Locations of Anomalies Test Pitted During Focused Remedial
Investigation 2-5
LIST OF TABLES
Table Title Page No.
2-1 Results of Product and Soil Analyses for Focused Remedial
Investigation 2-6
2-2 Alternatives Evaluated for the Interim Remedial Action at Site 11 . 2-9
2-3 Comparative Analyses of Source Control Remedial Alternatives . . . 2-11
2-4 Synopsis of Potential Federal and State Action-Specific ARARs . . . 2-16
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GLOSSARY
AOC area of concern
ARARs applicable or relevant and appropriate requirements
bis below land surface
CAA Clean Air Act
CAMU corrective action management units
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
FAC Florida Administrative Code
FDEP Florida Department of Environmental Protection
FDER Florida Department of Environmental Regulation
FFS Focused Feasibility Study
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FS Feasibility Study
IAS Initial Assessment Study
IROD Interim Record of Decision
LDR
mg/kg
/ig/kg
MSDS
NAS
NAAQS
NCP
NPL
NSPS
Land Disposal Restrictions
milligrams per kilogram
micrograms per kilogram
micrograms per liter
Material Safety Data Sheets
Naval Air Station
National Ambient Air Quality Standards
National Oil and Hazardous Substances Pollution Contingency Plan
National Priority List
New Source Performance Standards
OSHA
OU
PEL
ppb
PPE
RCRA
RFI
RI
ROD
Occupational Safety and Health Administration
Operable Unit
permissible exposure limit
parts per billio.n
personal protection equipment
Resource Conservation and Recovery Act
RCRA Facility Investigation
Remedial Investigation
Record of Decision
SARA
Superfund Amendments and Reauthorization Act
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MVL08.94
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GLOSSARY (Continued)
TSD treatment, storage, and disposal
TU temporary units
USEPA U.S. Environmental Protection Agency
VOCs volatile organic compounds
yd3 cubic yards
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1.0 DECLARATION FOR THE INTERIM RECORD OF DECISION
1.1 SITE NAME AND LOCATION. The site name is the Golf Course Pesticide Disposal
Area, Site 11, Operable Unit (OU) 6. The site is located in a wooded area
between the llth fairway and the 17th green at'the Naval Air Station (NAS) Cecil
Field golf course, Jacksonville, Florida.
1.2 STATEMENT OF BASIS AND PURPOSE. This decision document presents the
selected interim remedial action for source control at OU 6 or Site 11, the Golf
Course Pesticide Disposal Area. The selected interim remedial action was chosen
in accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP, 40 Code of Federal Regulations [CFR] ,
Part 300). This decision document explains the factual basis for selecting the
interim remedy for Site 11 and the rationale for the final decision. The
information supporting this interim remedial action decision is contained in the
Administrative Record for this site.
The purpose of the interim remedial action is to remove buried containers of
pesticides and associated contaminated soil. The U.S. Environmental Protection
Agency (USEPA) and the Florida Department of Environmental Protection (FDEP)
concur with the selected interim remedy.
1.3 ASSESSMENT OF THE SITE. Actual or threatened releases of hazardous
substances from the site, if not addressed by implementing the response actions
selected in the Interim Record of Decision (1ROD), may present an imminent and
substantial endangerment to public health, welfare, or the environment as a
result of concentrations of contaminants in soil and groundwater in excess of
health-based levels, if the contents of the containers is released into the
environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY. The preferred alternative for source
control at Site 11 is a combination of two alternatives (Alternatives 1 and 3)
that were developed and evaluated in the Focused Feasibility Study (FFS). The
combined preferred alternative would meet the Resource Conservation and Recovery
Act (RCRA) Land Disposal Restriction (LDR) requirements. A combination of
Alternatives 1 and 3 would involve:
• excavation of contaminated debris (i.e., empty, partially full, full, or
leaking pesticide containers);
• repackaging (overpacking) of full, partially full, and leaking
containers in an area where spills are controlled with subsequent
sampling of contents for waste profiling;
• excavation of contaminated soil;
• testing of excavated soils to determine if treatment is required prior
to disposal (i.e., if the soils are subject to LDRs);
CF_S11_I.ROD
MVL08.94 1 -1
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• onsite treatment of contaminated debris (i.e., empty containers) using
high pressure water washing;
transportation and disposal of decontaminated debris to a solid waste
landfill;
transportation of full, partially full, or leaking pesticide containers
for offsite incineration;
• transportation and disposal of soil with concentrations below the LDR
treatment standards to a hazardous waste landfill;
transportation, treatment, and disposal in a hazardous waste landfill of
all soil with concentrations of hazardous constituents that are higher
than the LDR treatment standards;
• transportation, treatment (if necessary), and disposal of water used in
high pressure water washing of hazardous debris; and
• backfilling of excavated areas with clean soil.
The Navy estimates that the preferred alternative would cost between $708,000 and
$1,772,000 and would take 5 weeks to implement. The range in cost is dependent
on the amount of excavated material that has concentrations of hazardous
constituents above the LDR treatment standard and, therefore, must be treated
prior to land disposal.
1.5 STATUTORY DETERMINATIONS. This interim action is protective of human health
and the environment, complies with Federal and State applicable or relevant and
appropriate requirements (ARARs) for this limited scope action, and is cost
effective. Although this interim action is not intended to fully address the
statutory mandate for permanence and treatment to the maximum extent practicable,
this interim action uses treatment and, thus, is in furtherance of that statutory
mandate. Because this action does not constitute the final remedy for soil and
groundwater at Site 11, the statutory preference for remedies that employ treat-
ment that reduces toxicity, mobility, or volume as a principal element, although
partially addressed in this remedy, will be addressed by the final response
action for soil and groundwater. Subsequent actions are planned to address fully
the threats posed by the conditions in the soil and groundwater at this site.
Because this is an interim action Record of Decision (ROD), review of this site
and of this remedy will be ongoing as the Navy continues to develop final
remedial alternatives for this site and this OU.
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF THE REMEDY
I
Captain Kirk T. Lewis // I
Commanding Officer, NAS^ecil Field Date
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MVL08.94 1 -2
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2.0 DECISION SUMMARY
2.1 SITE NAME. LOCATION. AND DESCRIPTION. NAS Cecil Field is located 14 miles
southwest of Jacksonville in the northeastern part of Florida. Most of NAS Cecil
Field is located within Duval County; however, part is located in the northern
part of Clay County.
NAS Cecil Field was established in 1941 and provides facilities, services, and
material support for the operation and maintenance of naval weapons, aircraft,
and other units of the operating forces as designated by the Chief of Naval
Operations. Some of the tasks required to accomplish this mission include
operation of fuel storage facilities, performance of aircraft maintenance,
maintenance and operation of engine repair facilities and test cells for turbo-
jet engines, and support of special weapons systems.
Site 11 is located in a wooded area on the golf course within the NAS Cecil Field
property as shown on Figure 2-1. The area around Site 11 is covered with dense
undercover. An access road and several small trails that traverse the area
appear to be well maintained and free of vegetation. The greens and fairways
located east and west of Site 11 are flat and grassy. The golf course
maintenance area located southeast of the site consists of several small
buildings and sheds with asphalt and concrete ground cover. A sketch of Site 11
is provided on Figure 2-2.
Surface runoff in the immediate vicinity of Site 11 flows into the golf course
drainage system, which eventually drains to Rowell Creek. There is little to no
surface runoff at the site itself due to the dense vegetation.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES. Site 11 was used by golf course
maintenance personnel for the disposal of empty, partially full, and full
pesticide containers from the early 1970's until 1978. Containers were
reportedly buried in a pit approximately 40 feet wide by 40 feet long. This pit
was reportedly (Envirodyne Engineers, 1985) located at the golf course between
fairways 11 and 17 (Figure 2-2).
Previous studies indicated that approximately two to four empty 5-gallon cans
were disposed per month within the pit. The cans were not rinsed prior to
disposal. The cans were allowed to accumulate for a number of months before they
were crushed by a front-end loader and buried approximately 3 feet deep. It was
estimated that a total of 200 to 450 containers were crushed and disposed within
the pit.
After completion of the new pesticide facility (Building 397) in 1978, 2 to 3
full 30-gallon containers of unused pesticides, at least 1 of which reportedly
contained l,2-dibromo-3-chloropropane (trade name Nemagon"1) , a pesticide used to
control nematodes, and approximately 10 to 15 full or partially full 5-gallon
containers of pesticides, herbicides, and fungicides were discarded and buried
at the site because they were considered unusable for the new facility.
Reportedly, many of these containers were beginning to rust and lacked iden-
tification labels. Once the move was made to the new facility, use of Site 11
for container disposal purposes was discontinued (Harding Lawson Associates,
1988).
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MVUOB.94 2-1
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LAKE
I
N
A
INSTALLATION BOUNDARY
3500 7000
SCALE: 1" = 7000'
FIGURE 2-1
SITE LOCATION MAP
CECIL/DECISION.dwg/NP/4- 28-9*
INTERIM RECORD OF DECISION
SITE 11
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
CF_S11_I.ROO
MVL08.94
2-2
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FIGURE 2-2
STUDY AREA
CECIL\11MAP\?-WDW\08-24-94
INTERIM RECORD OF DECISION
SITEtl
MAS CECIL FIELD
JACKSONVILLE, FLORIDA
CF_S11_I.ROD
MVL08.94
2-3
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To date there has been no enforcement activities at the site.
2.3 PREVIOUS INVESTIGATIONS. Previous environmental investigations at Site 11
include an Initial Assessment Study (IAS) , an RCRA Facility Investigation (RFI),
and a Focused Remedial Investigation (RI). The results of these investigations
are summarized below.
Initial Assessment Study. The IAS was performed in 1985 by Envirodyne Engineers
to identify waste sites at NAS Cecil Field that warranted further investigation.
The study included an investigation of historical data and aerial photographs as
well as field inspections and personnel interviews. A total of 18 sites were
identified as a result of the IAS, including Site 11.
RCRA Facility Investigation. The RFI was performed in 1988 by Harding Lawson
Associates. Field investigations completed for Site 11 included a geophysical
survey using a. magnetometer to locate subsurface features, the installation of
two monitoring wells, collection and analysis of two groundwater samples and two
soil samples, and measurement of water levels in the two monitoring wells.
Groundwater samples contained inorganics such as chromium (332 and 40 micrograms
per liter [ng/$.]) and lead (573 and 59 fig/Ji"). The analytical results of the two
soil samples collected from the suspected pesticide container burial pit
indicated the presence of volatile organic compounds (VOCs) such as methylene
chloride (24 micrograms per kilogram [A«g/kg]), toluene (16 Mg/kg), and 1,1,1-
trichloroethane (24 and 39 /zg/kg).
Focused Remedial Investigation. A Focused RI at Site 11 was conducted by ABB
Environmental Services, Inc., from July to October 1993 to define the volume,
location, and characteristics of the reportedly buried pesticide containers.
This investigation was accomplished by clearing the understory and vegetation,
conducting a geophysical survey to verify the presence of disturbed soil and
identify anomalies, test pitting anomalies to characterize the contents, sampling
and analyses of pesticide products found in partially full or leaking containers,
and sampling and analyses of soil suspected of pesticide contamination.
Approximately 40 percent of the areal extent of the site was investigated using
modified Level D personal protection equipment (PPE). The remaining 60 percent
of the work was -executed in Level B PPE. The upgrade of PPE was necessary
because of the possible presence of l,2-dibromo-3-chloropropane. Personal air
monitoring for 1,2-dibromo-3-chloropropane was conducted during test pitting
using Gillian™ model HFS 113A pumps with low flow adapters and petroleum-based
charcoal tubes. All test pit workers were on supplied air. In the breathing
zone of test pit workers, atmospheric concentrations ranging from 1 to 4 parts
per billion (ppb) of l,2-dibromo-3-chloropropane were detected, which is above
the permissible exposure limit (PEL) of 1 ppb.
The geophysical survey indicated 19 anomalies in the area of Site 11. These
areas are shown on Figure 2-3. Test pits were excavated at these locations to
verify the presence of pesticide containers. Pesticide containers were found in
Anomalies 4, 5, 7, 8, and 16. All other anomalies contained either nothing or
non-hazardous debris. The results of the product and soil sampling are provided
in Table 2-1. Pesticides were found in three of the six product samples. Pesti-
cides and metals were found in the soil sample from Anomaly 4. Despite extending
the investigation beyond the originally designated site, the reported deposit of
200 to 450 containers was not found. A total of 41 empty containers, 7 full or
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MVL.08.94 2-4
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\ r \\
FORMER BORROW\ \
ANOMALY 18
300 FEET
LEGEND
Monitoring well location
fj i Areas of anomaly
Dense trees and underbrush
Approximate limits of
site clearing and
geophysical explorations
50
100
SCALE: 1" = 100'
FIGURE 2-3
LOCATIONS OF ANOMALIES TEST PITTED
DURING FOCUSED REMEDIAL INVESTIGATION
CECIL\SURVEY\,MAH-WOW\ 08-24-93
INTERIM RECORD OF DECISION
SITE 11
NAS CECIL FIELD
JACKSONVILLE, FLORIDA
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MVL08.94
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Table 2-1
Results of Product and Soil Analyses for
Focused Remedial Investigation
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Sample Compound Detected Type
Product No. 1 alpha-BHC' Pesticide
gamma-BHC Pesticide
2,4-D2 Pesticide
Product No. 5 1,2-Dibromo-3-chloropropane3 Pesticide
Toxaphene Pesticide
Product No. 6 1 ,2-Dibromo-3-chloropropane3 Pesticide
Soil No. 1 1,2-Dibromo-3-chloropropane3 Pesticide
Parathion Pesticide
Aluminum Metal
Arsenic Metal
Barium Metal
Chromium Metal
Copper ' Metal
Iron Metal
Magnesium Metal
Zinc Metal
1 Benzene hexachloride.
2 Dichlorophenoxyacetic acid.
3 Trade name Nemagon».
Notes: Samples collected from containers are referred to as product.
There was no product No. 4 sample collected or analyzed.
Soil No. 1 was collected from Anomaly 4.
No hazardous substances were detected for products No. 2, 3, and 7.
mg/kg = milligrams per kilogram.
fjg/t = micrograms per liter.
pg/kg = micrograms per kilogram.
Concentrations
0.085 mg/kg
0.60 mg/kg
47 mg/kg
680 fjg/t
73fjg/t
340,000 ijg/l
160pg/kg
330pg/kg
1,690 mg/kg
46.6 mg/kg
3.4 mg/kg
4.6 mg/kg
1.2 mg/kg
623 mg/kg
5.0 mg/kg
6.0 mg/kg
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partially full containers, and 3 50-pound bags of powder were found during the
investigation. All full, partially full, and leaking containers were placed into
overpack drums. A variety of nonhazardous debris including pipes, concrete,
tires, scrap metal, and bottles were encountered during test pitting.
2.4 HIGHLIGHTS OF COMMUNITY PARTICIPATION. The FFS report and Proposed Plan
were completed and released to the public in February 1994. A public meeting was
held on March 8, 1994, to present information on the proposed interim remedial
action at Site 11 and to solicit comments on the proposed cleanup. These
documents and other Installation Restoration program information are available
for public review in the Information Repository and Administrative Record. The
repository is maintained at the Charles D. Webb Wesconnett Branch of the
Jacksonville Public Library in Jacksonville, Florida. The notice of availability
of these documents was published in The Florida Times Union on February 27, 1994,
and March 6, 1994.
A 30-day public comment period was held from March 2, 1994, to April 1, 1994.
At the public meeting on March 8, 1994, representatives from NAS Cecil Field,
USEPA, FDEP, and the Navy's environmental consultants presented information on
the remedial alternatives and answered questions regarding the proposed interim
remedial action at Site 11. No written comments were received during the public
comment period; however, questions asked during the public meeting are summarized
and addressed in Appendix A, Responsiveness Summary.
2.5 SCOPE AND ROLE OF INTERIM REMEDIAL ACTION. Investigations at Site 11
indicated that pesticide containers were deposited in several locations within
the site. The purpose of this interim remedial action is to remove the source
of contamination to soil and groundwater at Site 11; namely, the debris and the
contaminated soil encountered during removal of the pesticide containers at the
site. Based on previous investigations and the evaluation of ARARs for this
site, the following remedial action objectives were identified:
• reduce migration and volatilization of pesticide contaminants to the
surrounding environment at the site by removing pesticide wastes,
containers, and associated obviously contaminated soil; and
• characterize wastes removed from the site.
Upon completion of the overall Remedial Investigation and Feasibility Study
(RI/FS) for Site 11, the need for remedial action to address soil or groundwater
contamination will be evaluated. This IROD addresses interim source control
(i.e., removal of pesticide containers) remedial actions only. It is believed
that this interim action is consistent with any future remedial activities that
may take place at the site.
2.6 SITE CHARACTERISTICS. The geophysical surveys and test pitting have
characterized approximately 2.5 acres at Site 11 to a depth of approximately 10
feet below land surface (bis). The reported deposit of 200 to 450 buried empty
pesticide containers was not located during this investigation. The geophysical
survey and test pits have identified five anomalies where containers with
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MVL08.94 2-7
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pesticides were found buried and another six anomalies where miscellaneous debris
was located. A total of 41 empty containers, 7 full or partially full
containers, and 3 bags were found during this investigation.
The volume of soil and the number of pesticide containers that require removal
from Site 11 are developed from the descriptions of materials encountered during
test pitting of magnetic anomalies. The volume of soil to be excavated for this
remedial action was based on a maximum expected excavation depth of 5 feet bis
at Anomaly 4 and 2 feet bis at Anomalies 5, 7, 8, and 16 (Figure 2-3). It is
assumed that soil from anomalies where pesticide containers were found would
require excavation during the interim remedial action. This includes Anomalies
4, 5, 7, 8, and 16. The depth of excavation was based on the extent of disturbed
soils identified during the Focused RI. Based on these assumptions, a maximum
of 360 cubic yards (yd3), including a 10 percent bulking factor, would be
excavated from the site during the interim remedial action.
The number of full, partially full, or leaking pesticide containers to be removed
from the site was estimated based on observations made by field personnel during
the Focused RI. Anomaly 4 contains an estimated 190 pounds of empty pesticide
containers and one 50-pound bag of powder requiring removal from the site.
Approximately 360 pounds of empty pesticide containers and one full 50-pound bag
of solid material require removal from Anomalies 5, 7, 8, and 16 and the surface.
2.7 SUMMARY OF SITE RISKS. The insecticide Nemagon™ contains l,2-dibromo-3-
chloropropane, which is the contaminant of concern at Site 11. This compound has
an Occupational Safety and Health Administration (OSHA) PEL of 1 ppb, cannot be
detected adequately by any real-time monitoring instrumentation, is absorbed
through all routes of entry into the body (inhalation, ingestion, dermal, and
eye), can cause breakthrough in impermeable work clothing, and causes cancer,
atrophy of the testicles in men, changes in the estrous cycle in women, liver
disease, kidney disease, skin disease, and blood disorders.
The purpose of this interim remedial action is to remove pesticide wastes and
debris, which are currently acting as sources of soil contamination at Site 11.
A baseline risk assessment has not been completed at this time. Once the
overall RI has been completed, the baseline risk assessment will be completed
using RI data and any risks associated with exposure to contaminated soils and/or
groundwater at Site 11 will be addressed in a subsequent FS.
Results of the Focused RI indicated that pesticide containers were deposited in
several locations within the site. The results of the sampling and analyses are
presented in Table 2-1 (Subsection 2.2.2). In sufficient quantity, these
compounds represent a potential human health and environmental risk if contacted,
ingested, or allowed to migrate freely in surface water, soil, sediment, air, or
groundwater. Removal and appropriate management of wastes and containers with
residues of these compounds will reduce the risk posed to human health and the
environment.
2.8 DESCRIPTIONS OF ALTERNATIVES. Table 2-2 presents a description of the
source control alternatives evaluated for Site 11. The alternatives are numbered
to correspond with the alternatives provided in the FFS report (available at the
Information Repository).
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MVL08.94 2-8
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Table 2-2
Alternatives Evaluated for the Interim Remedial Action at Site 11
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Reid, Jacksonville, Rorida
Alternative
Alternative 1: Excavation and
offsite Incineration of contami-
nated soil; onsite treatment of
contaminated debris with offsite
disposal of treated debris.
Alternative 2: Excavation and
offsite incineration of contami-
nated soil; offsite treatment
and disposal of contaminated
debris.
Alternative 3: Excavation
and offsite disposal of con-
taminated soil; onsite treat-
ment of contaminated de-
bris with offsite disposal of
treated debris.
Alternative 4: Excavation
and offsite disposal of con-
taminated soil, and offsite
treatment and disposal of
debris.
Alternative 6: Excavation
and offsite disposal of
contaminated soil and
debris.
Total Cost
$1,772,000
$1,770,000
$708,000
$705,000
$749,000
Sol
Transport contaminated soil
to offsite Incinerator.
Transport contaminated
soil to offsite Incinerator.
Transport contaminat-
ed soil to an offsite
hazardous waste land-
fill.
Transport contaminated
soil to an offsite hazard-
ous waste landfill.
Transport contaminat-
ed soil to an offsite
hazardous waste land-
fill.
Debris
ro
cb
Treat contaminated debris
onsite using high-pressure
water washing.
Transport treated debris off-
site for disposal in a solid
waste landfill.
Transport contaminated
debris to an offsite
hazardous waste
treatment facility for treat-
ment and disposal.
Treat contaminated
debris onsite.
Transport treated
debris to offsite solid
waste landfill.
Transport contaminated
debris to offsite hazard-
ous waste treatment
facility for treatment
and disposal.
Transport contaminat-
ed debris to an offsite
hazardous waste land-
fill.
Activities
common to all
alternatives
1. Clear and prepare the site. 4.
2. Excavate contaminated debris, Including full, partially full, and 5.
leaking containers. 6.
3. Stage all pesticide containers; sample contents of partially full 7.
and leaking containers. 8.
Excavate contaminated soil.
Sample excavated soil.
Transport full, partially full, and leaking containers to offsite incinerator.
Backfill excavated areas with native soil.
Demobilize and restore site to its previous condition.
-------
All alternatives involve excavation of contaminated debris, including full,
partially full, and leaking pesticide containers. Additionally, all alternatives
include excavation, transport, and disposal of up to 360 yd3 of contaminated soil
and transport, thermal treatment, and disposal of full, partially full, and
leaking pesticide containers. All alternatives involve disposal of both soil
and debris in either hazardous waste or solid waste landfills.
Four alternatives were developed to consider whether debris should be treated
onsite or offsite and whether contaminated soil should be disposed in a hazardous
waste landfill or incinerated prior to disposal. The fifth alternative assumed
all soil and untreated debris would be placed in a hazardous waste landfill and
would require a variance for landfilling of untreated debris.
Evaluation of a no action alternative, typically required in a Feasibility Study,
is not necessary in an FFS because designation of an interim remedial action
implies that some action should be taken.
2.9 SUMMARY OF COMPARATIVE ANALYSES OF ALTERNATIVES. This section evaluates
and compares each of the alternatives with respect to the nine criteria used to
assess remedial alternatives as outlined in Section 300.430(e) of the NCP. A
comparative analysis of source control remedial alternatives for the nine
criteria is provided in Table 2-3.
2.9.1 Overall Protection All alternatives would provide an increased level of
protection of human health and the environment. Risks are reduced by removing
pesticides, pesticide containers, and contaminated soil from the site, thereby
preventing exposure and reducing a source of soil and potential groundwater
contamination.
2.9.2 Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs). All alternatives meet ARARs with one possible exception. Alternative
5 can be implemented only if a Subtitle C landfill capacity regulatory variance
extension is granted (and the landfill agrees to accept untreated hazardous
debris because capacity is available). No chemical-specific or location-specific
ARARs were identified for this interim remedial action. A complete listing of
action-specific ARARs is listed in Table 2-4.
2.9.3 Long-term Effectiveness and Permanence The reduction of risk at Site 11
is permanent for all alternatives because pesticide containers, contaminated
soil, and debris would be removed from the site. Constituents remaining after
soil and debris excavation would not pose a direct-contact hazard and would be
addressed during future soil and groundwater remediation if they are determined
to pose a risk.
2.9.4 Reduction of Toxicity. Mobility, or Volume of the Contaminants
Alternatives 1, 2, and 4 would achieve significant and permanent reduction in
toxicity, mobility, and volume of product and contaminants on debris and in soil.
Alternative 3 would result in a significant and permanent reduction of toxicity,
mobility, and volume of contaminants on debris; the toxicity of soil would not
be reduced because contaminated soil would be transported offsite to a hazardous
waste landfill. Alternative 4 would reduce the mobility and volume of
contaminants of soil and debris onsite, but would not reduce the toxicity of
CF S11J.ROD
MvLoa.94 2-10
-------
$':-
ro
Table
Comparative Analyses of Source
Interim Record
2-3
Control Remedial Alternatives
of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Reid, Jacksonville, Rorida
Criterion
Overall Protection of Human
How risks are eliminated,
reduced, or controlled
Short-term or cross-media
effects
Compliance with ARARs
Chemical-, location-, and
action-specific ARARs
Alternative RA-1
Health and the Environment
Alternative RA-1 would
provide an increased level of
protection to human health
and the environment because
risks via direct contact with or
inhalation of pesticide con-
taminants at the site are
minimized. Worker health
and safety requirements
would be maintained.
No short-term adverse effects
are expected to occur during
implementation of this alter-'
native. Care will be taken to
prevent cross-media con-
tamination during remedial
action.
Would comply.
Alternative RA-2
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Alternative RA-3 Alternative RA-4
Analysis is the same as Analysis Is the same as
for Alternative RA-1. Soil for Alternative RA-1. Soil
would not be treated would not be treated prior
prior to disposal. to disposal.
Analysis is the same as Analysis is the same as
for Alternative RA-1. for Alternative RA-1.
If concentrations of pes- Analysis is the same as
ticide contaminants in for Alternative RA-3.
sol) do not meet the land
ban criteria, this alter-
native would not meet
ARARs.
Alternative RA-5
Analysis is the same as
or less than that for
Alternative RA-1.
Neither soil nor debris
would be treated prior
to disposal.
Analysis is the same as
for Alternative RA-1.
If concentrations of pes-
ticide contaminants in
soil and on debris do
not meet the land ban
criteria, this alternative
would not meet ARARs.
See notes at end of table.
-------
2°
s
8'r-
ro
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Field, Jacksonville, Rorida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Long-term Effectiveness and Permanence
Magnitude of
residual risk
Adequacy of
controls
Reliability of controls
Reduction of Mobiity,
Treatment process
and remedy
Amount of
hazardous material
destroyed or treated
The reduction in risk at Site 1 1
would be permanent because pes-
ticide containers would be removed
from the site. Other contaminated
media at the site remaining after
implementation of the remedial
action would be addressed in the
overall FS for Site 11. Risk as-
sociated with hazardous
constituents in soil and on debris Is
reduced through treatment or
destruction of these constituents.
Implementation of alternative would
provide immediate and long-term
source control at Site 11.
Incineration is highly reliable. High
pressure washing is reliable as long
as wash water is contained.
Toxicity, and Volume
Contaminated nonporous debris
would be treated via high pressure
washing. Generated water would
also be treated. Soil would be
treated via incineration.
Approximately 550 pounds of
empty and 165 pounds of full
pesticide containers and 360 yd3 of
soil would be treated for this
alternative.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1;
however, the
Implementation of this
alternative is less
favorable than Alternative
RA-1 because no
treatment of
contaminated soil is
employed.
Analysis is the same as
for Alternative RA-1.
Landfilling of wastes is
reliable. High pressure
washing is reliable as
long as wash water is
contained.
Contaminated debris
would be treated via
high pressure washing.
Generated water would
also be treated. No
treatment processes
would be implemented
for contaminated soil.
550 pounds of empty
and 165 pounds of full
pesticide containers
would be treated for this
alternative.
Analysis is the same as
for Alternative RA-1;
however, the
implementation of this
alternative is less
favorable than Alternative
RA-1 because no
treatment of
contaminated soil is
employed.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-3.
Analysis is the same as
for Alternative RA-3.
Analysis is the same as
for Alternative RA-3.
•
Analysis is similar to
Alternative RA-1 but
because pesticide
contaminants are not
destroyed, only their
mobility and potential
for exposure to
receptors will be
reduced, the reduction
is less than Alternative
RA-1.
Analysis is the same as
for Alternative RA-1.
Disposal of soil and
debris is reliable.
No treatment processes
would be employed to
treated contaminated
soil or debris.
This alternative does
not provide for treat-
ment of contaminated
soil or debris.
See notes at end of table.
-------
s °
N)
CO
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Reduction of Moblhy. Toxfcity, and Volume (Continued)
Reduction of
mobility, toxicity,
or volume through
treatment
Irreversibility of
treatment
Type and quantity
of treatment
residuals
Short-term
Effectiveness
Protection of
community during
remedial action
Protection of
workers during
remedial actions
Would achieve significant and permanent
reduction In toxicity, mobility, and volume
of contaminants on debris and in soil.
Incineration and high pressure washing are
irreversible.
Approximately 480 gallons of wash water
would be produced that would require
further treatment and disposal. Ash would
be produced during incineration but would
be managed by the offslte incineration
facility.
Dust control would be required during
excavation of soil. Fact sheets and posters
providing Information to the public
regarding the remedial action would be
distributed. Transportation of wastes offsite
poses a specific level of risk.
Workers would be required to follow an
approved Health and Safety Plan. Workers
within the exclusion zone would be dressed
in Level B protection and would be on a
special medical monitoring program.
Analysis is the same as
for Alternative RA-1.
Analysis Is the same as
for Alternative RA-1.
Wash water and ash
would be produced
during Implementation
of this alternative, but
both residuals would be
managed by the offsite
treatment facility.
Analysis is the same as
for Alternative RA-1.
Analysis is the same as
for Alternative RA-1.
Would achieve significant and
permanent reduction In
toxicity, mobility, and volume
of contaminants on debris.
No reduction in toxicity of
contaminants in soil.
High pressure washing of
debris is irreversible.
Approximately 480 gallons of
wash water would be
produced that would require
further treatment and
disposal.
Analysis is the same as for
Alternative RA-1.
Analysis is the same as for
Alternative RA-1.
Analysis is the same
as for Alternative
RA-3.
Analysis is the same
as for Alternative
RA-3.
Wash water would be
produced during
Implementation of
this alternative, but
would be managed
by the offsite
treatment facility.
Analysis is the same
as for Alternative
RA-1.
Analysis is the same
as for Alternative RA-
1.
No reduction in the
toxicity of
contaminants on
debris or in soil.
Not applicable.
No treatment
residuals would be
produced if this
alternative were
implemented.
Analysis is the
same as for
Alternative RA-1.
Analysis is the
same as for
Alternative RA-1.
See notes at end of table.
-------
&
ro
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11. OU 6
MAS Cecil Reid. Jacksonville, Florida
Criterion
Alternative RA-1
Alternative RA-2
Alternative RA-3
Alternative RA-4
Alternative RA-5
Short-term Effectiveness (Continued) '
Environmental effects
Time until remedial
action objectives are
achieved
Implementablity
Ability to construct
technology
Reliability of
technology
Ease of undertaking
additional remedial
action, if necessary
Monitoring
considerations
No effects to surrounding environment
expected. Releases to air are expected to
have minimal environmental effect based
on the results of the dust monitoring
conducted during the Focused Rl.
Approximately 5 weeks are necessary to
meet the remedial action objectives for
Site 11.
High pressure washer would be delivered
prefabricated to the site.
Treatment standards for contaminated
debris and soil would be achieved via high
pressure washing and Incineration,
respectively.
Would provide no Impediment to additional
remediation.
Air monitoring would be conducted as
appropriate during excavation,
transportation, and debris treatment.
Medical monitoring of workers within the
exclusion zone would be required.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
No construction
necessary.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1,
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
High pressure washer
would be delivered
prefabricated to the
site.
Treatment standards
for contaminated
debris would be
achieved via high
pressure washing.
Regulated landfills are
designed and
constructed to
minimize leaching of
contaminants.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
No construction
necessary.
Analysis is the same
as for Alternative RA-3.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
No technology
construction
necessary.
Regulated landfills are
designed and
constructed to
minimize leaching of
contaminants.
Analysis is the same
as for Alternative RA-1.
Analysis is the same
as for Alternative RA-1.
See notes at end of table.
-------
fc'r-
fji
_A
Ol
Table 2-3 (Continued)
Comparative Analyses of Source Control Remedial Alternatives
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Field, Jacksonville, Florida
Criterion Alternative RA-1
Implementabiity (Continued)
Coordination with other Coordination with NAS Cecil Field
regulatory agencies personnel required for duration of
remedial activities. Coordination with
county, USEPA, FDEP, and TSD for
incinerator necessary.
Availability and capacity Availability of permitted TSD facilities
of treatment, storage, for treatment of contaminated soil
and disposal services would be required at the time of
remedial action. Vendors that provide
equipment necessary for high
pressure washing are available.
Availability of tech- Construction contractors, equipment,
nofogies, equipment, and and laboratories are available.
specialists
Ability to obtain Approval from State and USEPA
approvals from other necessary prior to offsite treatment of
agencies contaminated soil.
Cost
Capital Costs $1,541,000
Total present worth $1,772,000
(including contingency)
Notes: TSD = treatment, storage, and disposal.
NAS = Naval Air Station.
ARAB = applicable or relevant and appropriate requirements.
FS = feasibility study.
Alternative RA-2 Alternative RA-3
Analysis is the Analysis Is the same as for
same as for Alternative RA-1.
Alternative RA-1.
Less coordination
necessary than for
onsite treatment
of debris.
Analysis is the Availability of landfills
same as for permitted to accept excavated
Alternative RA-1. soil would be required at the
time of remedial action. Ven-
dors that provide equipment
necessary for high pressure
washing are available.
Analysis is the Analysis is the same as for
same as for Alternative RA-1.
Alternative RA-1.
Analysis is the Approval from State and
same as for USEPA necessary prior to
Alternative RA-1. offsite disposal of con-
taminated soil.
$1,539,000 $615,000
$1,770,000 $708,000
Alternative RA-4
Analysis is the
same as for
Alternative RA-1.
Less coordination
necessary than
for onsite
treatment of
debris.
Analysis is the
same as for
Alternative RA-3.
Analysis is the
same as for
Alternative RA-1.
Analysis is the
same as for
Alternative RA-3.
$613,000
$705,000
Alternative RA-5
Analysis is the same as
for Alternative RA-1.
Availability of landfills
permitted to accept ex-
cavated soil and debris
would be required at
the time of remedial
action.
Analysis is the same as
for Alternative RA-1.
Approval from State
and USEPA necessary
prior to offsite disposal
of contaminated soil
and debris.
$651,000
$749,000
yd3 = cubic yard.
Rl = remedial investigation.
USEPA = U.S. Environmental Protection Agency.
FDEP = Rorida Department of Environmental Protection.
-------
Table 2-4
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record or Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Field, Jacksonville, Florida
Federal and State Stan-
dards and Requirements
Requirements Synopsis
Applicable or Relevant and Appropriate
Consideration In the Remedial Response Process
ro
o>
Clean Air Act (CAA), Na-
tional Ambient Air Quality
Standards (NAAQS) (40
Code of Federal Regula-
tions [CFR] Part 50)
CAA, New Source Perfor-
mance Standards (NSPS)
(40 CFR Part 60)
Resource Conservation
and Recovery Act
(RCRA), Standards for
Owners and Operators of
Hazardous Waste Treat-
ment, Storage, and
Disposal Facilities (TSDF)
(40 CFR Part 264)
Establishes primary (health-based) and
secondary (welfare-based) standards for air
quality for carbon monoxide, lead, nitrogen
dioxide, particulate matter, ozone, and
sulfur oxides.
This regulation establishes NSPS for
specified sources, including incinerators.
This rule establishes a particulate emission
standard of 0.08 grains per dry standard
cubic foot corrected to 12 percent carbon
dioxide for sources.
This rule establishes minimum national
standards that define the acceptable
management of hazardous wastes for
owners and operators of facilities that treat,
store, or dispose of hazardous wastes.
Relevant and Appropriate. This rule is not
strictly applicable because the source of
contamination (i.e., dust from excavation)
is not a "major source" based on volume of
release of the regulated contaminant.
Applicable. The new source performance
standards must be met by the incinerator
employed for offslte treatment.
Applicable. The minimum standards must
be met for treatment of hazardous debris
on site.
Relevant and Appropriate. Minimum
standards must be met for treatment of
debris contaminated with material which is
significantly similar to a hazardous waste.
Site remedial activities must comply with NAAQS. The
most relevant pollutant standard is for particulate matter
less than 10 microns in size (PM,0) as defined in 40 CFR
Section 50.6. The PM,0 standard is based on the detri-
mental effects of particulate matter to the lungs of hu-
mans. The PM10 standard for a 24-hour period is 150
micrograms per cubic meter (/t/g/m3) of air, not to be
exceeded more than once a year. Remedial con-
struction activities such as excavation will need to
include controls to ensure compliance with the PM,0
standard. The attainment and maintenance of primary
and secondary NAAQS are required to protect human
health and welfare (wildlife, climate, recreation,
transportation, and economic values). These standards
are applicable during remedial activities, such as soil
excavation, that may result in exposure to hazardous
chemicals through dust and vapors.
Because NSPS are source-specific requirements, they
are not generally considered applicable to
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) cleanup
actions. However, an NSPS may be applicable for an
incinerator; or may be a relevant and appropriate re-
quirement If the pollutant emitted and the technology
employed during the cleanup action are sufficiently
similar to the pollutant and source category regulated.
If a remedial alternative for Site 11 involves the
management of RCRA wastes at an offsite treatment,
storage, or disposal unit, the substantive requirements
of this rule would be an applicable or relevant and ap-
propriate requirement (ARAR).
-------
Table 2-4 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Florida
Federal and State
Standards and
Requirements
Requirements Synopsis
Applicable or Relevant and Appropriate Consideration in the Remedial Response Process
ro
RCRA, Use and
Management of
Containers (40 CFR Part
264, Subpart I)
RCRA, Incinerators (40
CFR Subpart O, 264.340-
264.599)
RCRA, Manifest System,
Recordkeeping, and
Reporting (40 CFR Part
264, Subpart E)
Hazardous Materials
Transportation Act (49
CFR Parts 171, 173, 178,
and 179) and Hazardous
Materials Transportation
Regulations
RCRA, Standards
Applicable to
Transporters of
Hazardous Waste (40
CFR Part 263, Subparts
A -C, 263.10-263.31)
Sets standards for the storage of containers
of hazardous waste.
This regulation specifies the performance
standards, operating requirements, and moni-
toring, inspection, and closure guidelines for
any incinerator that manages hazardous
waste.
This rule outlines procedures for manifesting
hazardous waste for owners and operators of
onsite and offsite facilities that treat, store, or
dispose of hazardous waste.
These regulations outline procedures for the
packaging, labeling, manifesting, and
transporting of hazardous materials.
This rule establishes procedures for
transporters of hazardous waste within the
United States if the transportation requires a
manifest under 40 CFR Part 262.
Applicable. If waste Is hazardous, these
requirements must be met for storage of
waste in containers.
Relevant and Appropriate. If waste is
significantly similar to a hazardous
waste, storage in containers must meet
these requirements.
Applicable. Offsite incinerator must
meet these requirements for treatment
of hazardous wastes.
Applicable. If waste is hazardous, these
requirements must be met for
transportation of waste offsite.
Applicable. If waste is hazardous, these
requirements must be met for
transportation of hazardous waste
offsite.
Applicable. If waste to be transported
offsite is hazardous, these requirements
must be met.
Any remedial action implemented at Site 11 would
involve the storage of containers of RCRA hazardous
waste. The staging of study-generated RCRA wastes
should meet the intent of this regulation. These require-
ments are relevant and appropriate for containerized
wastes at CERCLA sites.
These requirements are applicable for remedial actions
involving the offsite incineration of RCRA-regulated
wastes.
These regulations apply if a remedial alternative
involves the offsite treatment, storage, or disposal of
hazardous waste. For remedial actions Involving onsite
treatment or disposal of hazardous waste, these regula-
tions are applicable.
For remedial actions involving offsite treatment, storage,
or disposal, contaminated media materials would need
to be packaged, manifested, and transported to a
licensed offsite facility in compliance with these regu-
lations.
If a remedial alternative involves offsite transportation of
hazardous waste for treatment, storage, or disposal,
these requirements must be attained.
-------
Table 2-4 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Federal and State
Standards and
Requirements
Requirements Synopsis
Applicable or Relevant and Appropriate Consideration In the Remedial Response Process
r\i
oo
RCRA, Standards
Applicable to
Generators of
Hazardous Waste
(40 CFR Part 262,
Subparts A - D,
262.10-262.44)
RCRA, Hazardous
Waste Management
System
(40 CFR Part 260)
RCRA, Identification
and Listing of
Hazardous Waste
(40 CFR Part 261,
261.1-261.33)
These rules establish standards for generators of
hazardous wastes that address: accumulating
waste, preparing hazardous waste for shipment,
and preparing the uniform hazardous waste
manifest. These requirements are integrated with
U.S. Department of Transportation (DOT)
regulations.
Sets forth procedures that the U.S. Environmental
Protection Agency (USEPA) will use to make
information available to the public and sets forth
rules that TSDFs must follow to assert claims of
business confidentiality with respect to information
submitted to the USEPA pursuant to 40 CFR Parts
261-265.
This rule defines those solid wastes that are subject
to regulation as hazardous wastes under 40 CFR
Parts 262-265. The applicability of RCRA
regulations to wastes found at a site is dependent
on the solid waste meeting one of the following
criteria: (1) the wastes are generated through a
RCRA listed source process, (2) the wastes are
RCRA-listed wastes from a non-specific source, or
(3) the waste is characteristically hazardous due to
ignitability, corrositivlty, reactivity, or toxicity.
Applicable. If waste to be disposed of
offsite is hazardous, these requirements
must be met.
Applicable. Where wastes disposed
offsite are hazardous, the requirements
of this rule must be met.
Applicable. The criteria for identifying
wastes, as defined by this rule, must be
met.
If an alternative involves the offsite transportation of
hazardous wastes, the material must be shipped in
proper containers that are accurately marked and
labeled, and the transporter must display proper
placards. These rules specify that all hazardous waste
shipments must be accompanied by an appropriate
manifest.
Whereas this regulation does not stipulate substantive
cleanup requirements, it details confidentially proce-
dures for offsite TSDFs.
Full pesticide containers removed from Site 11 may be
classified as RCRA wastes. If a container is labeled,
the chemical constituents of the container may be
identified from respective Material Safety Data Sheets
(MSDS). If a container is not labeled, the contents of
the container will be analyzed for RCRA characteristics
that include pesticides (including 1,2-dibromo-3-
chloropropane) suspected to be disposed at the site.
Excavated soil will be analyzed to identify any hazard-
ous constituents contained in the soil. All soils and
containers will be managed in accordance with this
regulation. Residuals from the treatment of hazardous
debris (e.g., decontamination water) may be classified
as RCRA hazardous waste. Treatment residuals will be
sampled, analyzed, and disposed based on the
analytical results.
-------
Table 2-4 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Field, Jacksonville, Rorida
Federal and State
Standards and
Requirements
Requirements Synopsis
Applicable or Relevant and
Appropriate
Consideration in the Remedial Response Process
N>
CO
RCRA, Land
Disposal Restrictions
for Newly Usted
Wastes and
Hazardous Debris
(40 CFR Parts 148,
260, 261, 262, 264,
265, 270, and 271)
RCRA, Corrective
Action Management
Units; Corrective
Action Provisions
Under Subtitle C (40
CFR Parts 260, 264,
265, 268, 270, and
271)
RCRA, Land
Disposal Regula-
tions (LDRs) (40
CFR Part 268)
This rule sets forth five options for management of
hazardous debris: (1) treat the debris to performance
standards established in this rule through one of 17
approved technologies, (2) obtain a ruling from USEPA
that the debris no longer contains hazardous waste, (3)
treat the debris using a technology approved through an
"equivalent technology demonstration,* (4) treat the
debris to existing Land Disposal Restriction (LDR)
standards for wastes contaminating the debris and
continue to manage under RCRA Subtitle C, or (5)
dispose of debris in a Subtitle C landfill under the
generic extension of the capacity variance for hazardous
debris, which currently expires on May 8, 1994.
This rule establishes corrective action management units
(CAMU) and temporary units (TUs) as two options for
corrective actions at permitted RCRA facilities.
This rule establishes restrictions for the land disposal of
untreated hazardous wastes and provides treatment
standards for these land-banned wastes. Under this
rule, treatment standards have been established for
most listed hazardous wastes.
Applicable. This rule is applicable for
treatment of hazardous debris onsite.
Relevant and Appropriate. These
requirements must be met for onsite
treatment of debris contaminated with
waste that is significantly similar to
hazardous waste.
Applicable. Storage and treatment of
hazardous wastes onsite would be
subject to these requirements.
Relevant and Appropriate. Storage
and treatment of wastes that are
determined to be significantly similar
to hazardous wastes would be
subject to these requirements.
Applicable. If the waste is
characterized as a RCRA hazardous
waste, the RCRA-contaminated sub-
stance is to be "placed" (i.e., moved
from the site to a landfill), and the
waste is to be land disposed, LDRs
would apply.
Relevant and Appropriate. The land
disposal restrictions must be met if
the waste is significantly similar to the
RCRA-hazardous waste.
Debris at Site 11 (i.e., empty pesticides containers)
would be classified as hazardous debris if it is
contaminated with RCRA listed waste that has LDR
standards or with waste that exhibits a toxic
characteristic. Under CERCLA, removal of contami-
nants from debris by decontamination and replacing
the debris within an area of concern (AOC) is per-
mitted. As long as movement of waste is conducted
within the AOC and outside of a separate RCRA unit,
placement of wastes have not occurred and,
therefore, LDRs are not triggered. However, if the
debris is determined to be hazardous, and place-
ment is determined to occur, one of the five listed
options must be selected for management of the
hazardous debris.
The substantive requirements of this rule is a
potential ARAR at Site 11 because hazardous wastes
would be stored onsite for any remedial alternative
implemented.
Treatment standards for wastes removed at Site 11
would be established upon completion of testing of
materials. If it is determined that wastes removed
from Site 11 are subject to these regulations, then
the wastes must be treated prior to disposal in a
RCRA Subtitle C landfill.
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fc'r-
Table 2-4 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
NAS Cecil Reid, Jacksonville, Rorida
Federal and State
Standards and
Requirements
Requirements Synopsis
Applicable or Relevant and Appropriate
Consideration in the Remedial Response Process
N»
RCRA. Contingency
Plan and
Emergency
Procedures (40 CFR
Subpart D, 264.30-
264.37)
Occupational Safety
and Health Act
(OSHA), General
Industry Standards
(29 CFR Part 1910)
OSHA,
Recordkeeping,
Reporting, and
Related Regulations
(29 CFR Part 1904)
OSHA Health and
Safety Standards
(29 CFR Part 1926)
RCRA, General
Facility Standards
(40 CFR Subpart B,
264.10-264.18)
This regulation outlines the requirements for
procedures to be followed in the event of an
emergency such as an explosion, fire, or other
emergency event.
This act requires establishment of programs to
assure worker health and safety at hazardous
waste sites, including employee training require-
ments.
Provides recordkeeping and reporting require-
ments applicable to remedial activities.
Specifies the type of safety training, equipment,
and procedures to be used during site investiga-
tion and remediation.
Sets the general facility requirements including
general waste analysis, security measures, in-
spections, and training requirements.
Applicable. Treatment, storage, and disposal
of hazardous wastes would be subject to these
requirements.
Relevant and Appropriate. Onsite storage and
treatment of wastes which are determined to be
significantly similar to hazardous wastes would
be subject to these requirements.
Applicable. OSHA requirements apply to all
site work involving hazardous wastes.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that are significantly similar to hazardous
wastes.
Applicable. OSHA requirements apply to all
site work.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that are significantly similar to hazardous
wastes.
Applicable. OSHA requirements apply to all
site work.
Relevant and Appropriate. OSHA requirements
apply to sites involving work with substances
that are significantly similar to hazardous
wastes.
Applicable. Any offsite TSDF employed to
treat, store, or dispose of hazardous waste
would be subject to these requirements. Stora-
ge and treatment of hazardous wastes onsite
would also be subject to these requirements.
Relevant and Appropriate. Storage and
treatment of wastes that are determined to be
significantly similar to hazardous wastes would
be subject to these requirements.
These requirements are relevant and appropriate
for remedial actions involving the management of
hazardous waste.
Under 40 CFR 300.38, requirements apply to all
response activities under the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP). During remedial action at the site, these
regulations must be maintained.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work. During remedial action at the site,
these regulations must be maintained.
All phases of the remedial response project should
be executed In compliance with this regulation.
During remedial action at the site, these regula-
tions must be maintained.
Because the remedial action planned for Site 11
involves the management of RCRA wastes at an
offsite TSDF, these requirements are applicable.
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S
Table 2-4 (Continued)
Synopsis of Potential Federal and State Action-Specific ARARs
Interim Record of Decision
Golf Course Pesticide Disposal Area, Site 11, OU 6
MAS Cecil Held, Jacksonville, Rorida
Federal and State
Standards and
Requirements
Requirements Synopsis
Applicable or Relevant and Appropriate
Consideration in the Remedial Response
Process
ro
ro
RCRA, Preparedness
and Prevention (40
CFR Part 264,
Subpart C)
Chapter 17-736,
Florida Administrative
Code (FAC),
Rorida Rules on
Hazardous Waste
Warning Signs, July
1991
Federal Insecticide,
Fungicide, and
Rodenticide Act
(FIFRA) (40 CFR Part
165)
RCRA, Solid Waste
Land Disposal
Requirements (40
CFR Part 258)
This regulation outlines
requirements for safety equip-
ment and spill-control for
hazardous waste facilities.
Facilities must be designed,
maintained, constructed, and
operated to minimize the possi-
bility of an unplanned release
that could threaten human
health or the environment.
Requires warning signs at
National Priority Ust (NPL) and
Rorida Department of Environ-
mental Regulation (FDEP;
formerly Rorida Department of
Environmental Regulation
[FDER]) identified hazardous
waste sites to inform the public
of the presence of potentially
harmful conditions.
Provides procedures for the
storage and disposal of
pesticides, pesticide related
wastes, and their containers.
This rule sets forth requirements
for disposal of waste within a
solid waste landfill. Also sets
forth construction and
monitoring requirements of
Subtitle D landfills.
Applicable. Any offsite TSDF employed to treat,
store, or dispose of hazardous waste would be sub-
ject to these requirements. Storage and treatment
of hazardous wastes onsite would also be subject to
these requirements.
Relevant and Appropriate. Storage and treatment
of wastes which are determined to be significantly
similar to hazardous wastes would be subject to
these requirements.
Applicable. Warning signs must be placed on NPL
sites.
Applicable. Specified pesticides must be managed
according to the requirements established In this
rule.
Applicable. The requirements established in this
rule are applicable to waste determined to be non-
hazardous.
Safety and communication equipment should be
incorporated into all aspects of the remedial
process and local authorities should be familiar-
ized with site operations.
Because Naval Air Station (NAS) Cecil Reid is
currently listed on the NPL, this requirement is
applicable.
FIFRA requirements are action-specific ARARs for
pesticide-contaminated media. Remedial
alternatives for Site 11 would include provisions
for drumming, storing, and disposing pesticide
contaminated wastes; FIFRA requirements must
be met.
This rule stipulates that no free liquids, no
hazardous wastes, and no reactive wastes may be
deposited within a Subtitle D landfill.
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contaminants in either soil or debris because contaminants would be transferred
to an offsite hazardous waste landfill.
2.9.5 Short-Term Effectiveness Dust control would be required during
excavation of soil. Volatilization of the contaminants would be monitored and
controlled during excavation and transport. Releases to the air are expected to
have minimal environmental effect based on the results of the dust monitoring
conducted during the Focused RI.
2.9.6 Implementabilitv It is expected that all alternatives would be
implementable at Site 11. Equipment and services necessary for the removal,
treatment, and disposal of contaminated media at Site 11 are readily available.
2.9.7 Cost The range of cost for the two preferred alternatives (Alternatives
1 and 3) is $1,772,000 to $708,000, respectively. A range is provided because
the volume of soils requiring thermal treatment is not known at this time but
will be evaluated during implementation of the interim remedial action. The most
expensive alternative is Alternative 1 because offsite thermal treatment of
contaminated soil by incineration and onsite treatment of contaminated debris is
costly.
2.9.8 State and Federal Acceptance The FDEP and USEPA have concurred with the
Navy's selection of a combination of these alternatives.
2.9.9 Community Acceptance The community has accepted the selected remedy.
No written comments were received during the public comment period. In general,
comments raised during the public meeting on March 8, 1994, supported the
selected alternatives and the expedient implementation of the interim remedial
action.
2.10 SELECTED REMEDY. The preferred alternative for source control at Site 11
is a combination of Alternatives 1 and 3. The combination of these alternatives
would meet the LDR requirements by transporting contaminated soil above the LDR
treatment standards offsite for incineration prior to disposal and transporting
contaminated soil below the LDR standards to a hazardous waste landfill. Every
20 yd3 of excavated soil will be sampled and analyzed to determine pesticide
contaminant concentrations. In addition, contaminated debris will be treated
onsite using high-pressure water washing prior to disposal of treated debris in
a solid waste landfill. A combination of Alternatives 1 and 3 is protective of
the environment, a permanent remedy, and cost effective.
The interim remedial action at Site 11 will be conducted in Level B PPE due to
the possible exposure to l,2-dibromo-3-chloropropane. The Navy estimates that
the preferred alternative would cost between $708,000 and $1,772,000 and would
take 5 weeks to implement.
2.11 STATUTORY DETERMINATIONS. The interim remedial action selected for
implementation at Site 11 is consistent with CERCLA and the NCP. The selected
remedy is protective of human health and the environment, attains ARARs, and is
cost effective. The selected remedy also satisfies the statutory preference for
treatment that permanently and significantly reduces the mobility, toxicity, or
volume of hazardous substances as a principal element. Additionally, the
CF_S11_I.ROD
MVLoa.94 2-22
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selected remedy uses alternate treatment technologies or resource recovery
technologies to the maximum extent practicable. Any soil contamination remaining
onsite after this interim remedial action will be addressed during the RI and FS
for this OU and the resulting ROD.
2.12 DOCUMENTATION OF SIGNIFICANT CHANGES. There are no significant changes in
the interim remedial action from that described in the Proposed Plan.
CF_S11 I.ROD
MVL08.94 2-23
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REFERENCES
ABB Environmental Services, Inc. (ABB-ES), 1993, Handbook of Applicable or
Relevant and Appropriate Requirements for Navy Sites within the State of
Florida: prepared for the Department of the Navy, Southern Division,
Charleston, South Carolina, August 1993.
ABB-ES, 1994a, Focused Feasibility Study, Site 11, Operable Unit 6, Source
Control Remedial Alternatives, NAS Cecil Field, Jacksonville, Florida:
prepared for the Department of the Navy, Southern Division, North
Charleston, South Carolina, January 1994.
ABB-ES, 1994b, Proposed Plan for Interim Remedial Action, Naval Air Station,
Cecil Field, Site 11, Golf Course Pesticide Disposal Area, Jacksonville,
Florida: prepared for the Department of the Navy, Southern Division, North
Charleston, South Carolina, February 1994.
Envirodyne Engineers, 1985, Initial Assessment Study of Naval Air Station Cecil
Field, Jacksonville, Florida: prepared for Naval Energy and Environmental
Support Activity (NEESA), NEESA 13-073, Port Hueneme, California, July
1985.
Harding Lawson Associates, 1988, RCRA Facility Investigation, NAS Cecil Field,
Jacksonville, Florida.
USEPA, 1988, Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA, Interim Final: Office of Solid Waste and Emergency
Response, Washington, DC, October 1988.
USEPA, 1990a, National Oil and Hazardous Substances Pollution Contingency Plan:
40 CFR Part 300, Washington, DC, March 1990.
USEPA, 1990b, A Guide to Developing Superfund Records of Decision, Quick
Reference Fact Sheet: Office of Emergency and Remedial Response,
Washington, D.C., 9335.3-02FS-1, May 1990.
USEPA, 1991, Guide to Developing Superfund No Action, Interim Action, and
Contingency Remedy RODs, Quick Reference Fact Sheet: Office of Emergency
and Remedial Response, Washington, D.C., 9335.3-02FS-3, April 1991.
CF_S11J.ROD
MVL08.94 Ref-1
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APPENDIX A
RESPONSIVENESS SUMMARY
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Responsiveness Summary
Site 11 Source Control Remedial Alternatives
NAS Cecil Reid, Florida
Comment
Response
QUESTIONS FROM THE PUBLIC MEETING
Why did you choose onslte treatment of
debris versus offsite?
Did you look at the groundwater or just at
the soil at this time?
How deep were the monitoring wells that
were installed?
The fact sheet indicates that there were also
some solvents found at the site.
Is the estimated time to complete the
alternatives in years or months?
After the soil is thermally treated, why is it
not placed back in the excavation?
So, thermally treated soil is still considered
contaminated soil?
In the feasibility study, it mentioned that an
explosive training device was found at one
of the sites. Is there a possibility of
explosives at this site or is that remote?
Onsite treatment for the debris was selected to avoid hauling containers of pesticides through communities to a disposal
area. The cost differential was not significant, and because of the positive aspect of treating the waste at the source, it was
determined to be more appropriate.
Just the soil. During an earlier field investigation (1987) two groundwater monitoring wells were installed at Site 11.
Groundwater samples collected at both monitoring wells indicated no pesticide contamination in the groundwater. The
overall Remedial Investigation and Feasibility Study program is designed to install additional monitoring wells to further
characterize soil and groundwater contamination at the site.
The screened Interval of the monitoring wells were from 10 feet below ground surface to 40 feet below ground surface.
Additional monitoring wells will be screened over a shorter interval across the water table surface and at the deeper parts of
the surficial aquifer.
During an earlier investigation conducted in 1987, some solvents were found in two soil samples. The solvents that were
found in the soils included toluene, a common petroleum product that could have been used to cut or dilute and process the
pesticides; 1,1-trichloroethane (TCA), another common solvent that could have derived from practices other than the
pesticide operation; and methylene chloride, used commonly as a paint thinner and paint stripper, and may be derived from
that type of waste disposal practice. The concentrations of these chemicals in the soil were very low; in the order of 20 to 40
micrograms per kilogram.
The estimated time to complete each of the alternatives for the interim remedial action at site 11 is 5 weeks.
After offsite thermal treatment of the soils is completed, the soil is still considered a hazardous waste. Regulatory
requirements state that the soils must go into a permitted hazardous waste landfill.
In the hazardous waste regulatory system, thermally treated soil is still considered hazardous for land disposal purposes.
Total petroleum hydrocarbon contamination without the hazardous waste constituents, are treated in a different manner.
It is a remote possibility that unexploded ordnance will be encountered at this site. However, part of the cleanup operations
for all alternatives includes a provision to handle unexploded ordnance, If encountered.
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fe'r-
Responsiveness Summary-continued
Site 11 Source Control Remedial Alternatives
NAS Cecil Field, Florida
Comment
Response
QUESTIONS FROM THE PUBLIC MEETING
(continued)
How will the soil that comes out of the
ground be classified? What type of F
codes, U codes, K codes, apply?
Do you run an analytical test on all the soil
before it goes offsite in order to classify it?
From your investigations, how long have
the drums that were filled with pesticide
containers been sitting there?
Based on what you found so far, what is
the estimated volume, in gallons, that was
likely disposed of at Site 11 ?
At least one U-type waste, 1,2,-dibromo-3-chloropropane (U-66), has been identified to be present at the site. If we find
a U-type listed waste, then that would be a Resource Conservation and Recovery Act (RCRA) hazardous waste and must
be managed accordingly. Otherwise, the soil would be evaluated based on its hazardous characteristics.
Yes.
Overpacked drums have been sitting aboveground since the end of the field investigation (October 1993).
In the test pits, 41 empty containers (1- to 55-gallon containers), 7 full or partially full containers, and 3 50-pound bags of
yellow powder were uncovered. Because it was an undocumented disposal operation, it is difficult to determine an
accurate volume in gallons of what was deposited.
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